Skip to content
GovernanceDPO

IIA Three Lines Model (2020) for DPOs

What does IIA Three Lines Model (2020) require of a DPO?

The IIA's principles-based model for organising governance roles: what the governing body, management (which carries first-line and second-line work), internal audit (the third line) and external assurance providers each contribute, how they stay independent yet aligned, and how together they create and protect value. Under IIA Three Lines Model (2020), which defines 12 controls, a DPO's work is deciding which controls you own outright, which you share and which belong to another team, then holding the evidence for the first group.

Which IIA Three Lines Model (2020) controls land on the DPO

Data Protection Officers oversee privacy compliance, manage data subject rights requests, conduct privacy impact assessments, and serve as the point of contact with data protection authorities. The role is mandatory under GDPR for many organisations.

IIA Three Lines Model (2020) defines 12 controls across 2 domains that directly affect the DPO role. Understanding which controls fall within your ownership, which are shared, and which are owned by other teams is the foundation of effective compliance management.

What a DPO is accountable for under IIA Three Lines Model (2020)

1

Advising the organisation on data protection obligations and best practices

2

Managing data subject access requests (DSARs) and privacy complaints

3

Conducting data protection impact assessments (DPIAs) for new processing activities

4

Maintaining records of processing activities and data flow maps

5

Serving as the liaison with data protection supervisory authorities

Where DPOs lose time on IIA Three Lines Model (2020)

These are the most common obstacles DPOs face when managing IIA Three Lines Model (2020) compliance, and how to address them:

Challenge 1

Maintaining visibility over all personal data processing across the organisation

Challenge 2

Managing cross-border data transfer compliance (SCCs, adequacy decisions)

Challenge 3

Keeping privacy notices and consent mechanisms current across all channels

Challenge 4

Responding to DSARs within regulatory timeframes at scale

Challenge 5

Assessing privacy implications of AI and automated decision-making systems

A working order for a DPO starting on IIA Three Lines Model (2020)

1. Readiness Assessment

Take a 5-minute readiness assessment to identify your organisation's current gap profile against IIA Three Lines Model (2020). Get a prioritised action plan tailored to your specific situation.

2. Cross-Framework Mapping

Use our platform to map IIA Three Lines Model (2020) controls against other frameworks you already comply with. Identify overlapping controls to reduce duplicate effort.

3. Build Your Toolkit

Equip yourself with IIA Three Lines Model (2020) toolkits, self-assessments, and implementation guides from our store. Resources designed specifically for DPOs managing compliance programmes.

4. Continuous Monitoring

Establish ongoing compliance monitoring using our platform's gap analysis tools. Track your maturity over time and demonstrate progress to stakeholders.

IIA Three Lines Model (2020) in your sector

Who else owns part of IIA Three Lines Model (2020)

Questions DPOs ask about IIA Three Lines Model (2020)

What does a DPO need to know about IIA Three Lines Model (2020)?
As a DPO, your key responsibilities under IIA Three Lines Model (2020) include advising the organisation on data protection obligations and best practices and managing data subject access requests (dsars) and privacy complaints. The framework contains 12 controls that fall within your area of responsibility. Understanding which controls you own versus which are shared with other teams is critical for effective implementation.
How does IIA Three Lines Model (2020) affect the DPO role?
IIA Three Lines Model (2020) directly impacts DPOs through advising the organisation on data protection obligations and best practices, managing data subject access requests (dsars) and privacy complaints, conducting data protection impact assessments (dpias) for new processing activities. The framework provides structure that helps DPOs demonstrate due diligence and report compliance status to stakeholders.
What are the biggest IIA Three Lines Model (2020) challenges for DPOs?
Common challenges include maintaining visibility over all personal data processing across the organisation; managing cross-border data transfer compliance (sccs, adequacy decisions); keeping privacy notices and consent mechanisms current across all channels. Using cross-framework mapping tools and automated evidence collection can significantly reduce these pain points.
How should a DPO prepare for a IIA Three Lines Model (2020) audit?
Start by conducting a readiness assessment to identify gaps. Then focus on conducting data protection impact assessments (dpias) for new processing activities and maintaining records of processing activities and data flow maps. Maintain a current evidence repository and ensure all control owners have documented their processes. Our readiness reports provide a prioritised action plan specific to your gap profile.
What tools help DPOs manage IIA Three Lines Model (2020) compliance?
Effective IIA Three Lines Model (2020) compliance management requires tools for gap analysis, control mapping, evidence collection, and reporting. Our compliance platform provides AI-powered gap analysis across 1,305 frameworks with 315K+ verified control-to-control mappings, helping DPOs identify overlapping requirements and reduce duplicate compliance effort.

DPO: How ready is your organisation for IIA Three Lines Model (2020)?

Answer 25 questions and get a professional readiness report with gap analysis, maturity scores, and prioritised action items. Results in 5 minutes.

Written and maintained by Gerard Blokdyk, The Art of Service.Last updated .